MPC Meets in New Orleans

The Members’ Participation Council (MPC) held a meeting on April 14–16, 2026, in New Orleans and online. The two-part MPC General Session featured:

• The MPC Chair Report, during which MPC Chair Amanda Barbera (Indiana) updated attendees on upcoming MPC Executive Committee activity (including upcoming educational programs and the committee’s outreach efforts), announced that the GA Best Practices Subgroup (chaired by Don Sirois, Executive Director of the Maine guaranty association) will begin its annual review of the best practices, encouraged members to attend the State GA Board Chairs Conference in Chicago in July, and welcomed new members Jan Graeber (Texas) and Geri Powell (Georgia).
• The NOLHGA Management Report, in which NOLHGA President Katie Wade updated attendees on progress made in NOLHGA’s workstreams to implement the Vision 2027 strategic plan, including plans to continue to bolster NOLHGA’s operational effectiveness by updating the organization’s business continuity and disaster recovery/incident response plans.
• An update on AssessConnect’s company database and assessment services platforms (one of the strategic plan workstreams) and development plans for 2026 by NOLHGA Chief of Staff Jenn Webb.
• Closed-session presentations by the task forces for Global Bankers Insurance Group (North Carolina), PHL Variable Insurance Company (Connecticut), and Senior Health Insurance Company of Pennsylvania (SHIP).
• The annual update on the operations of Guaranty Association Benefits Company (GABC), which administers the policies from the Executive Life of New York (ELNY) liquidation, by ELNY Task Force Chair John Colpean (Michigan) and Task Force Legal Counsel Kevin Griffith (Faegre Drinker Biddle & Reath).

The MPC meeting also featured:

• Meetings of the MPC Executive Committee, Assessment Data Survey Task Force, and Senior Health Insurance Company of Pennsylvania (SHIP) Task Force (closed session).
• A cybersecurity tabletop exercise conducted by Dan Hicks (NOLHGA) and Michael Denapoli (Pondurance).
• "Variable Product Rider Options," an educational presentation conducted by moderator Lori Geadelmann (Montana) and panelists Alfred Ayensu-Ghartey (Equitable) and Kevin Howard (Western & Southern Financial Group).
• "Where We’ve Been & Where We’re Going," a presentation on the mission and future plans of the Assessment Data Survey Task Force conducted by Co-Chairs Candie Kinch (Idaho, Oregon, and Wyoming) and Lindsay Crawford (NOLHGA) as well as Joanna Akiyama (NOLHGA), Tom Dawson (Strohm Ballweg), and Jacob Salzmann (Strohm Ballweg).

Global Insurance Symposium Highlights Private Credit, AI & Global Reinsurance

On April 14–15, 2026, the Global Insurance Symposium in Des Moines, Iowa, brought together domestic and international industry and regulators from across the country. Panels touched on recurring themes over the two days, including private credit, managing risks, and the output from AI. Here are some key takeaways:

• Private credit: Private credit emerged as a consistent focal point across the symposium. On a dedicated panel, industry representatives emphasized that (1) insurers’ private credit exposures are predominantly investment grade; (2) regulators have materially increased transparency and oversight, particularly with respect to credit ratings; and (3) risk management frameworks are well established. The NAIC’s Mark Sagat urged stakeholders to remember the “orders of magnitude” for private credit, noting that private credit remains a relatively small share of insurer portfolios, despite its recent growth. On the commissioners panel, Virginia Commissioner and NAIC President Scott White highlighted the NAIC workstreams completed or underway to strengthen solvency oversight in response to private credit and broader asset allocation trends.
• Artificial Intelligence: The symposium did not debut new regulatory requirements for AI risk management, but it highlighted a wide disparity in progress on regulators’ adoption of AI tools. Washington Commissioner Patty Kuderer described early use cases in her office, while South Dakota Director Larry Deiter noted that costs remain a barrier to deployment of AI. The NAIC’s Sagat characterized overall progress as “careful but growing,” noting some efforts underway to implement supervisory technology, or suptech.
• Global Reinsurance: A panel focused on global reinsurance explored international regulatory perspectives, the status of Bermuda and other cross-border jurisdictions, and industry views on deployment of capital and regulatory constraints. Kevin Clark of the Iowa Insurance Division emphasized that Bermuda’s reputation and relationships with U.S. regulators have improved over time, and that other emerging jurisdictions cannot achieve that overnight. He also said that, regardless of the strength of a cross-border regulatory regime, U.S. regulators cannot cede their responsibility to protect policyholders, which includes assessing risks related to reinsurance. Athene’s Mike Consedine warned about regulatory arbitrage, while asserting his company’s rigorous criteria for transferring risks to another jurisdiction. Former UK regulator Paul Sharma (now at Alvarez & Marsal) observed that Bermuda’s strength lies in its credibility and “reputation to lose” but cautioned that skepticism among central bankers toward jurisdictions that they do not regulate is unlikely to be overcome.

Federal Updates

The Department of Labor (DOL) and Employee Benefits Security Administration (EBSA) detailed “Guiding Principles for EBSA Enforcement Priorities” recently in a Field Assistance Bulletin. The DOL states it would (1) focus enforcement on the most “egregious conduct and significant harm,” including enforcement of loyalty breaches and non-exempt prohibited transactions; (2) avoid regulating through enforcement, including limiting novel theories of enforcement to ordinary regulatory practices; (3) require EBSA leadership to review “significant” enforcement activity; and (4) focus on responsive and timely enforcement, limiting routine investigations to 18 months and more complex investigations to 30 months.

In other federal news, at the CNBC “Invest in America Forum” on April 15, 2026, Treasury Secretary Scott Bessent fielded questions related to potential systemic risks from private credit. Two noteworthy takeaways from Bessent’s response: (1) he suggests that nothing in Treasury’s work has shown a systemic problem stemming from private credit; and (2) he cited Treasury’s recent decision to convene state insurance regulators to ensure no regulatory arbitrage is taking place. As part of those meetings, Treasury will have a forum for offshore reinsurance companies that buy private credit. Bessent emphasized that Treasury does not want to have any regulatory authority over insurers.

NAIC Updates

A new report published in the NAIC’s Journal of Insurance Regulation shows that the guaranty system provides protection to annuity purchasers without increasing moral hazard in the annuity market. In “Are Consumers Aware of State Insurance Guaranty Protections?”, authors David Blanchett (Head of Retirement Research for Prudential Financial, Inc., and a portfolio manager for PGIM), Michael Finke (Professor of Wealth Management at the American College of Financial Services), and Michael Guillemette (Assistant Professor at Texas Tech University) analyzed years of purchasing data in the multi-year guaranteed annuities (MYGA) market and concluded the protections provided by state life and health insurance guaranty associations did not prompt consumers to buy higher-risk products with benefits at or below guaranty association coverage levels. The report states that “sophisticated investors do not appear to take advantage of opportunities to earn higher returns below protection thresholds during periods of market turbulence when spreads between higher- and lower-quality insurers widen. Rules that shroud state guaranty protection appear to limit strategic purchases by sophisticated investors, potentially misallocating capital toward lower-rated insurers, while also protecting vulnerable consumers who appear to ignore insurer solvency ratings.”

To download a copy of the report, visit the NAIC’s website.

In other NAIC news, on April 12, 2026, Virginia Commissioner and NAIC President Scott White penned an opinion letter to The Wall Street Journal in response to a recent article on insurers’ private credit exposure. White’s letter explained that the 2024 NAIC report cited in that article has since been removed from the NAIC website. He went on to highlight several regulatory initiatives since 2018 to increase transparency and add guardrails on insurer investments, including the ability to challenge individual credit rating provider (CRP) ratings; enhanced oversight over NAIC Designations, private equity acquisitions, and reinsurance transactions; and the current efforts to develop a CRP due diligence framework.

The Life Actuarial Task Force (LATF) spent most of its April 16 call responding to the Society of Actuaries (SOA) work to revise its 2015 Valuation Basic Tables, which was initially discussed at the Spring National Meeting. The ACLI submitted a detailed comment letter, emphasizing that the SOA’s initial timeline may be unnecessarily aggressive and that industry would benefit from the creation of an aggregate table if additional splits are introduced. Regulators appreciated both points, and stakeholders noted that there is probably no need to rush through any analysis. The task force directed the SOA to include an aggregate table, which will add time to the ultimate work product. The SOA will continue its work and come back to the task force intermittently to provide updates. LATF also re-exposed APF 2026-03 for a 7-day comment period ending April 23; the proposal incorporates a slight technical change proposed by the ACLI. Task force members and NAIC staff agreed with the proposed change.

The Life Insurance and Annuities Illustrations Working Group scheduled two calls to review interested party feedback (due May 18) on a potential short-term approach to ensuring consumers receive reasonable expectations of annuity returns, including whether to build from Model #245, AG 49, or an alternative framework. The calls are scheduled for May 27 and June 2 at 12:00 p.m. Eastern.

International Developments

On April 14, 2026, the International Monetary Fund (IMF) released the April 2026 Global Financial Stability Report: Global Financial Markets Confront the War in the Middle East and Amplification Risks in its entirety (recall that only Chapter 2, regarding nonbank investors, was available previously). The IMF’s Monetary and Capital Markets Department discussed the following findings and insights during the press briefing:

• Financial Market Response to Middle East Conflict: The briefing underscored that the ongoing conflict in the Middle East is challenging global financial markets primarily through increased volatility, especially in energy prices. While markets have experienced bouts of turbulence, there have not been sustained drawdowns, forced margin calls, or major liquidity crises. Central banks have helped maintain orderly market functioning by providing liquidity facilities and improving market structures, such as through central clearing. However, the IMF noted that elevated public and private debt levels are making bond markets fragile in some countries, and the presence of leveraged investors is amplifying risks. The IMF stressed that ongoing monitoring, prudent macroprudential oversight, and readiness to inject liquidity are crucial to containing shocks.
• Private Credit Discussion: Several reporters raised questions regarding the increase in private credit fund redemptions, interconnectedness, and potential contagion risk. The IMF acknowledged recent activity and said it has performed considerable private credit analysis. Stress scenarios analyzed by the IMF suggest that, while default rates in private credit could rise to 4-6% under adverse conditions, these levels are considered manageable and not systemically threatening at present. In addition, the IMF stated that insurance companies and pension funds have some exposure, but the aggregate risk is contained.
• Risks Associated with Artificial Intelligence: Artificial intelligence was identified as both a significant opportunity and a source of emerging risks in the financial sector. The IMF noted that cyber risks associated with AI are substantial and require careful management, with global cooperation and strong regulatory frameworks being essential. The energy consumption of AI data centers was also raised as a consideration, with regional differences in energy supply affecting the impact. The IMF advised institutions and regulators to stay proactive and at the frontier of technological developments, ensuring that robust operational readiness and policy measures are in place to safeguard financial system integrity as AI adoption grows.

In other international news, Financial Stability Board (FSB) Chair Andrew Bailey sent a letter to the G20 finance ministers and central bank governors raising concerns that existing financial market vulnerabilities could be exacerbated by the conflict in the Middle East and urging international financial stability cooperation. These vulnerabilities include stretched asset valuations; highly concentrated leverage in the non-bank sector; and liquidity mismatches, opacity, and growing complexity within the private credit market. The letter previewed the FSB’s upcoming report on private credit vulnerabilities, which will discuss bank and private credit interlinkages, the creditworthiness of private credit borrowers, and challenges with valuing private credit assets. In addition, Bailey noted the growing interconnectedness between the life insurance sector and private equity and credit markets. The FSB intends to work with the International Association of Insurance Supervisors (IAIS) to support its life insurance structural shifts efforts.

AI Activity

In an April 13, 2026, letter to senior EU policymakers—including the European Commission, European Council, and European Parliament—the European Insurance and Occupational Pensions Authority (EIOPA) provided targeted recommendations on how the EU’s new Artificial Intelligence Act should be applied within the insurance sector. The letter explained that while the AI Act introduces a cross-sector, risk-based framework governing certain AI uses (including “high-risk” applications such as underwriting and pricing in life and health insurance), its interaction with existing EU insurance legislation (e.g., Solvency II, the Insurance Distribution Directive (IDD), and the Digital Operational Resilience Act (DORA)) raises practical implementation challenges.

EIOPA cautioned that, absent clarification, the regime could unintentionally capture long-established, transparent actuarial models and create duplicative or disproportionate compliance burdens for insurers and supervisors. In particular, EIOPA proposed excluding generalized linear models (GLMs) and generalized additive models (GAMs)—widely used, well-understood, and highly interpretable techniques—from the scope of the AI Act’s definition of AI systems, or at least from classification as “high-risk” systems.

Privacy Updates

On April 13, 2026, Virginia Governor Abigail Spanberger signed S.B. 388 into law, amending the Virginia Consumer Data Protection Act (VCDPA) to prohibit the sale of geolocation data. While entities regulated by the Gramm-Leach-Bliley Act (GLBA) remain exempt from the VCDPA, this amendment reflects growing regulatory scrutiny of geolocation data sales.

The U.S. House Committee on Energy and Commerce is planning to introduce a draft comprehensive privacy framework for consideration within the next two weeks. The bill is expected to take provisions from state comprehensive consumer privacy laws to create a federal preemptive standard.